Dale Goff, Owner Date: November 17, 2015

Goff Photography

880 E. Harney Lane

Lodi, CA 95242

Phone: (209) 366-1548

Email: dale@goffphotography.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request under Section 333

Dear Madam or Sir,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform 

Act”) and 14 C.F.R. Part 11, Goff Photography, seeks an exemption from the Federal 

Aviation Regulations (“FARs”) listed below:

14 C.F.R. Part 21

14 C.F.R. 45.23

14 C.F.R. 45.29

14 C.F.R. 61.23

14 C.F.R. 61.3

14 C.F.R. 61.113(a) & (b)

14 C.F.R. 61.133(a)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9

14 C.F.R. 91.109(a)

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203

14 CFR Subpart E (91.401 - 91.417)

The requested exemption would authorize unmanned aircraft operations using the DJI 

Inspire 1 for commercial precision photography for community and agriculture 

applications by Goff Photography, in the United States. These operations will be subject 

to strict operating requirements and conditions defined by the safety code of the 

Academy of Model Aeronautics. The requested exemption would permit Goff 

Photography to operate their DJI Inspire 1, which weigh less than 7 lbs., for 

Commercial, Real Estate and Agricultural Photography in support of the local 

community. The DJI Inspire 1 with onboard cameras to capture a high quality digital 

images and video that work with Adobe products to provide the enduser with quality 

imagery for commercial use. Use of the DJI Inspire 1 for aerial photography and video 
reduces the need to operate conventional aircraft for the same purpose and provides 

very high quality imagery at a fraction of the cost. These savings result in enhanced 

efficiency and productivity for the affected activities, as well as environmental benefits.

DJI Inspire Pilot training guide will be adopted by Goff Photography’s operator safety 

program. Operations under the exemption will be subject to strict operating 

requirements and conditions. This will ensure at least an equivalent level of safety to 

currently authorized flight operations using manned aircraft and under conditions as 

may be modified by the FAA as required by Section 333.

As described more fully below, the requested exemption would authorize commercial 

operations of aerial photography and video using the DJI Inspire 1. The DJI Inspire 1 is 

small in size at 6.47 lbs. The DJI Inspire 1 will be operated under controlled conditions 

at low altitude in airspace that is limited in scope. As described more fully herein; it will 

have automated control features, as described below. The DJI Inspire 1 also will be 

operated by an individual from Goff Photography that will be photographing or taking 

videos well within FAA’s requirements. Goff Photography will be offering their 

photography and video as a service to the community. Finally, the airspace in which the 

Unmanned Aerial System (UAS), will operate and disclosed area of operation to the 

FAA in advance.

Goff Photography respectfully submits this small, unmanned aerial vehicle because it 

will be used in lieu of comparatively hazardous operations. Operations currently 

conducted are with fixed wing and rotary conventional aircraft. The FAA can have 

confidence that the operations will achieve at least an equivalent level or greater level of 

safety. Approval of this exemption would thereby enhance safety and fulfill the Secretary 

of Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the 

Reform Act to “establish requirements for the safe operation of such aircraft systems in 

the national airspace system.” The nearest airport to Lodi is the Lodi Airport at 10.7 

miles from area of operation at its closest point.

As a local business, that is rooted in their community, Goff Photography promises to 

provide innovative products and dependable service to help its Community exceed their 

potential. Unmanned aerial technology is becoming a desirable tool in the commercial, 

real estate and agricultural industries. The unmanned aspect of aerial technology 

eliminates the endangerment of human life by low and slow flight and allows a safe and 

cost-effective acquisition of close-up aerial images. Goff Photography’s clients in this 

area are aware of FAA’s Rules and have asked Goff Photography to acquire a section 

333 exemption to comply with current mandate.

Given the technical specifications of the light weight DJI Inspire 1 especially, the type of 

operations, including flights above populated areas, Goff Photography believes it is 

relevant to use the Academy of Model Aeronautics (AMA) rules to meet the required 

level of safety in future operations with the DJI Inspire1. Indeed, the AMA has a proven 

track record in terms of providing safety guidelines for operators using ultra-light remote 

controlled aircrafts. Under this exemption, the operator would agree, if requested, to 
contact the FAA in order to provide the FAA with the details of the related missions and 

provide assurance that training and maintenance requirements are being met.

1. Characteristics of the Aircraft

The built-in flight control system is used to control the entire aircraft’s functions in flight. 

Such as, Pitch (forwards and backwards), Roll (left and right), Elevator (up and down) 

and Yaw (turn left or right). The flight controller contains the MC (Main Controller), IMU 

(Inertial Measurement Unit), GPS (Global Position System), compass, receiver and LED 

(Light Emitting Diode) indicators. The IMU has a built-in sensor and a barometric 

altimeter that measures both attitude and altitude. The compass reads geomagnetic 

information which assists the GPS (Global Position System) to accurately calculate the 

aircrafts position and height in order to lock the aircraft in a stable hover. The receiver is 

used to communicate with the remote controller and the MC acts as the brains of the 

complete flight control system connecting and controlling all the modules together. See 

DJI Inspire 1 Manual https://dl.djicdn.com/downloads/inspire_1/en/Inspire

%20_1_User_Manual__V1.8.pdf

2. Aircraft and Equivalent Level of Safety

The applicant proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate with the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

under the current regulatory structure because the proposed operations represent a 

safety enhancement to the already safe movie and television filming operations 

conducted with conventional aircraft.

These limitations and conditions to which Goff Photography agrees to be bound when 

conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 30 minutes. Flights will

 be terminated at 25% battery power reserve should that occur prior to the 30

 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more

 than 200 feet above an elevated platform from which filming is planned.

5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual

 Observer, and the Camera Operator.

6. sUAS pilot will be an FAA licensed airman with at least a private pilot's certificate

 and third class medical. The observer will hold at least a third class medical.

7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the 

 sUAS Pilot, who possess the necessary PIC qualifications, is also present on

 set (i.e. the Aerial Coordinator), that person can also be designated as PIC.

8. The UAS will only operate within a confined "Sterile Area" as defined in the Manual. 

 Section H, I and J of the Manual requires the establishment of a "Security Perimeter" 

 for the flight operations area.

9. A briefing will be conducted in regard to the planned sUAS operations prior to
 each day's production activities. It will be mandatory that all personnel who will be 

 performing duties within the boundaries of the safety perimeter be present for this 

 briefing.

10. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the 

 requested exemption, with the appropriate Flight Standards District Office.

11.The operator will obtain the consent of all persons involved in the filming and

 ensure that only consenting persons will be allowed within 100 feet of the flight 

 operation, and this radius may be reduced to 30 feet based upon an equivalent level 

 of safety determination, as required by Section K of the Manual. With the advanced 

 permission of the relevant FSDO, operations at closer range can be approved.

12.The operator will submit a written Plan of Activities to the FSDO three days before 

 the proposed shoot as required in Section K of the Manual.

13.Pilot and observer will have been trained in operation of UAS generally and received 

 up-to-date information on the particular UAS to be operated as required Sections M 

 and N of the Manual.

14. Observer and pilot will at all times be able to communicate by voice and/or text. 

15.Written and/or oral permission from the relevant property holders will be

 obtained.

16.AII required permissions and permits will be obtained from territorial, state,

 county or city jurisdictions, including local law enforcement, fire, or other

 appropriate governmental agencies.

17.1f the sUAS loses communications or loses its GPS signal, the UAS will have

 capability to return to a pre-determined location within the Security Perimeter and

 land.

18.The sUAS will have the capability to abort a flight in case of unpredicted

 obstacles or emergencies.

3. Operator Requirements

The DJI Inspire 1 is a light weight UAS platform made of Plastic body with no sharp or 

hard edges characterized by a high level of pre-programmed controls and various builtin technical capabilities (programming of a geo-fence and height limitations) that prevent 

the operator from doing a mission outside of the operating limits. All flights are Preprogrammed with DJI Go App, 6 satellites are needed to initiate take off with GPS 

guidance and do not require human intervention; nevertheless human override is 

possible by clicking one of the multiple “action” buttons or by using the remote controller 

provided with each DJI system. In the case of unplanned events either the autopilot 

reacts immediately, or the operator can choose between different pre-programmed or 

manual actions. Those procedures include a Flight Termination System (emergency 

landing procedure, triggered by the autopilot or the operator in charge: given its very 

light weight, the DJI Inspire 1 will initiate auto land sequence).

4. Conclusion

The value that the DJI Inspire 1 could bring to the commercial, real estate and 

agricultural industries is invaluable. It would bring several efficiency and production 

benefits to farming operations. This will allow Goff Photography to provide the local 

community, advertising and farmers with outstanding service in order to help them 
exceed their potential. Please allow Goff Photography to utilize the DJI Inspire 1 in their 

operations in a safe manner in accordance with AMA and FAA guidelines.

Sincerely,

 Dale Goff, Owner.